Preamble
What kind of future might there be for the psychological therapies if the HPC succeed in bringing them into their professions zoo? An otherwise lengthy trawl through this 'consultation' document to divine, through examining its entrails, an answer this question, has been handily truncated by the BACP's recent refusal to run with one of its major features: that state regulation takes the form of two qualitatively distinct titles 'psychotherapist' and 'counsellor'.
It is as though the PLG in their collaboration with the HPC had gone into a meadow that had grown freely for half a century and decided that in future only two kinds of the grass found there labeled, in traditional UK style, 1st and 2nd class, were to be considered legitimate. However, if it is true, as a BACAB executive has claimed, that his organisation had accredited over 100 thousand counsellors and counselling skills participants, it turns out there was a lot more counselling wheat than psychotherapy barley in the field.
Be that as it may… the BACP recently mailed its membership with a request for support in persuading the HPC to reject this differentiation in the recommendations we are considering. In a break from long-standing habit, the BACP, perhaps seeking to maintain a position of executive reasonableness, has asked their membership to give the various ruling psi elites a public no.
The BACP action almost certainly banjaxes psychological therapies regulation for the foreseeable future. Though they have staked out their opposition, the psychotherapists, pained to see so much hard work wasted, might concede that there is a spectrum of 'counsellerapy' but I can't see the HPC, when they come down from the wall, agreeing to either a single or a joint title. What would it be?
So bearing all this regulatory uproar in mind, what is worth saying about the PLG recommendations? The Standards of proficiency is a much more potently insidious document, see my a complementary review of it Calling all Therapists - Scorpio Rising. In the latter I presumed that I was writing for practitioners who have a considerable level of ambivalence and concern about the oncoming HPC regulation - if this is describes you, what might you need to know about all these shenanigans?
I suspect the best I can do is to supplement the Standards review with some gleanings from the very transparent HPC PLG recommendations and the not so transparent human relationships that powered them.
The Professional Liaison Group
First, what is the Professional Liaison Group [PLG] that has 'recommended' the future form and scope of the psychological therapies? In characteristic fashion the HPC called for nominations, then chose several layers of people; seven represented the main stakeholders, with ties to BACP, BPC, BABCP, BACAB, COSCA, Relate etc al. Obvious choices perhaps. Then there was the less obvious, even arbitrary layer of four people who seemed chosen for reason of geography, leverage and reputation, Professors Fonaghy and Cooper, J. Coe and J. MccMinn. A further layer of four, including the chair, could be seen as in-house HPC ballast to steady what has proved to be a predictably unstable raft. Lastly there were two 'lay' persons whose lay status was apparently legitimated by them being members of the HPC council.
The PLG were gathered together to make 'recommendations' about how the psychological therapies should be brought into state regulation. They met for five days, not long to reconfigure 100 years of psychopractice. And not, as PLG members discovered at the first meeting, whether they should be regulated. This exclusion of checking out the field's willingness to be regulated by the HPC excluded discussion of what might turn out to be a prescient element in the White Paper:
That whether or not the HPC could regulate the psychological therapies should depend on whether:
its system is capable of accommodating them.
Which for many practitioners is no longer an open question.
How so? The PLG Recommendations document, in its stiff statutory style tells us:
3. We undertook work to explore the statutory regulation of psychotherapists and counsellors in light of the conclusions of the White Paper.
Anyone who has followed the progress of the PLG deliberations in any detail might see the word 'explore' as economical with the truth. The Recommendations document conceals fairly successfully the extent to which the PLG were willing collaborators in the quite brutal forcing through of an HPC-defined agenda.
If you are trying to decide how to respond to the prospect of being state regulated you might perhaps beware of getting lost in the detail of the Recommendations, much of which is more relevant to training and educational establishments than individual practitioners. Suggestion, keep your eye the extent to which force, i.e. duress and coercion is the cultural style of the HPC you would be signing up to.
A series of reports in eIpnosis and HPCWatchDog have detailed the quality and content of the PLG's five days of meetings. Now we have their output. 31 A4 pages. Recommendations to the HPCouncil who in turn will consider the recommendations and pass them to the DoH lawyers to turn into a legislative amendment.
These documents are freely, though not that easily, available via the HPC web-site. I often wonder how many people apart from those paid to do the work actually ever look at them let alone study them carefully. It's not surprising they aren't much read, the texts often seem to bear the same relation to the PLG's reality as someone who, when asked how they are, reads a dated and timed diary of what they did in the last week -in the HPC's tightening grasp aimed at the seizure of control of the psychological therapies, everything that matters slips through their fingers.
Education and training
The PLG were tasked with making recommendations on the following key aspects of regulation:
Protected titles
Transfer of registers
Levels of entry to the register
Grandparenting period
Following the earlier observation that the Standards of proficiency are a more important window into what the HPC is up to, in this review I intend stepping over most of the HPC's précis of the PLG discussions to look at section 8 Education and training and to end by pointing to a couple of anomalies plus some remarks about the Consultation 'questions'.
Education and training tends to be a boring out of reach area of Regulatory activity but for the future of the psychological therapies it is perhaps the most important section of the Recommendations. If state regulation of the psychological therapies is installed, dozens of training businesses and not a few universities, stand to gain more than anyone else.
Following the PLG's recommendation of their draft Standards of proficiency for counsellors and psychotherapists, section 8.1of the PLG recommendations introduces the approval of education and training programmes based on these standards.
8.1.2. The HPC visits education and training providers to approve pre-registration education and training programmes against the standards of education and training.
8.1.3. The HPC programmes [are] delivered by Higher Education Institutions (HEIs), professional bodies and private providers. There is no requirement for an approved programme to be delivered or validated by a HEI.
The spectacles through which the HPC sees this provision can be seen from the huge number of institutions with courses for the HPC regulated healthcare professions that are presently accredited/visited. All of which, we may surmise, pay them for the endorsement. More on this below.
Later in section 8 we get to the conditions that might be thought to power the business dynamo driving state regulation.
8.1.7. If a programme is approved (having met any conditions if applicable), it is granted open ended approval subject to ongoing checks that the programme continues to meet the requisite standards via the annual monitoring and major change processes.
8.1.8. The HPC does not undertake cyclical re-visits of programmes (i.e. every five years).
8.1.9 …Once a programme is approved, someone who successfully completes that programme is eligible to apply for registration.
8.1.1 Opening of the Register
10. The HPC will approve all those education and training programmes, historic and current, that led or lead to registration with one of the voluntary registers that transfers.
It is easy to see why anyone dancing in the cascade of training/supervision/ supervisees/trainees business would welcome state regulation as something that consolidates their hold on this work.
While reviewing this section of the PLG report I coincidentally happened to open the HPC Approvals and Monitoring Annual report that I had picked up on a visit to Kennington Park Road. This has a training establishment visit schedule which reveals the scale of the educational approval that the HPC presently handles. The Approvals and Monitoring Annual report for 2006 lists HPC approved courses at around 80 universities and higher education institutions in the UK. A huge web of mutual dependence entailing (see visit reports link) considerable standardization and bureaucratization.
Also hidden in the HPC's quasi-legal presentation of the PLG recommendations is an intriguing circularity.
8.11. The Health Professions Order 2001 does not provide the HPC with a power to set the qualifications required for entry, but enables it to approve qualifications which meet the standards it has set for entry to the Register.
A wonderfully obtuse and elastic definition. And unless I am mistaken, an example of positive feedback - the Standards (again see the review of them) come to determine what can be approved and by default what is not in the standards will be likely to be neglected (students won't want to pay to study something the HPC has no interest in). By positive feedback I mean that the more there is of certain approved elements of training the more there will be of them and the less of what can safely be neglected. Isn't this a recipe for mediocrity and the suppression of innovation?
It also seems likely that a new training has to be born fully-formed i.e. with HPC approval, otherwise it won't attract students. Not a problem for existing institutions with sufficient resources to get on the merry-go-round but an obstacle, surely, to innovation.
This perspective on the HPC's effect on the future of the psychological therapies may be received as excessively rhetorical, and of course prophecy, especially with respect to the future, has a dubious record but this is how the PLG recommendations look to me.
Let's end this review with one or two other items of interest. Here is an uncharacteristically opaque paragraph from the PLG recommendations.
3.3.1 Terms of reference
14. The White Paper also said that the Government was planning to introduce statutory regulation for 'other psychological therapists'. The regulation of other occupational groups delivering psychological therapies was not directly within the PLG's terms of reference.
This seems a very cryptic statement. Who are these other psychological therapists'? And the regulation of other occupational groups delivering psychological therapies was not directly within the PLG's terms of reference.
Another area of unsettledness that may affect many practitioners is the following discussion:
4.4. 1
33. A smaller number of titles would be protected. For example, the 'stem titles' 'counsellor' and 'psychotherapist' might be protected. As the stem would be protected, this would cover usage of these titles as part of an adjectival title. For example, someone using the title 'psychodynamic' in front of psychotherapist would need to be registered.
4.4.2 Discussion
40. The PLG also took into account that a 'generic' approach would not limit or prevent practitioners from using adjectival / other titles in order to describe their modality or field of practice. Protecting the stem titles (e.g. 'psychotherapist' and 'counsellor') would mean that both someone using the title on its own, or with a preceding adjective, would need to registered.
This seems to be in sharp contrast to the advice in a recent message from the BPS (July 2009) in response to a query about the extent to which the generic title 'psychologist', which is not one of the seven protected 'psychologist' titles, could be used with an adjective, i.e. 'humanistic psychologist'. It elicited the following reply:
'Once HPC regulation begins there will be nothing to stop you using the standard 'psychologist' title or that of Holistic Psychologist'. It's only the adjectival and general titles noted at the Statutory Regulation FAQ's page that will be protected and you should be able to use any other titles than these.'
So that's all right then. I can call myself a 'humanistic psychologist' without fear of a 'cease and desist' notice from the HPC arriving in the post.
This review would not be complete without some mention of the consultation questions the HPC ask. At first sight all are 'how' questions, closed questions looking for 'yes' answers. Missing - are you convinced that the planned regulation will benefit your clients? Or do you feel that the PLG adequately represented your perspective as a practitioner? Hugely controversial notions such as 'safe and effective practice' are airily attached to 'threshold level of qualification for entry to the Register'.
When we do come to open questions they are under the heading 'Impact assessment'. Here in the word 'impact' the violence of the HPC's universe leaks out. An impact assessment reflects the reality of HPC regulation of the psychological therapies being a forced marriage; to quote the title of piece I wrote a while back, Chickens to wed fox and live together in henhouse. For clients counselling and psychotherapy are about relationship, relationship from which duress and coercion is absent. We should be under no illusions that in either these impact assessment questions or in the rest of the current consultation, Michael Guthrie and his boss Marc Seale are not making an offer of equable cooperation. They both know that it is a tank they are driving.
Appendix
List of educational establishments running HPC approved courses:
Guildhall School of Music and Drama
University of Abertay, Dundee
University of Chester
University of Essex
University of Nottingham
University of Lincoln
Glasgow Caledonian University
University of Hertfordshire
The Robert Gordon University
University of the West of England, Bristol
The University of Bolton
Queen Margaret University College, Edinburgh
Queen Margaret University Postgraduate College, Edinburgh
University of Wolverhampton
University of Greenwich
University of Kent
University of Northumbria at Newcastle
University of Plymouth
University of Leeds
University of Hertfordshire
University of Derby
Anglia Ruskin University
De Montfort University
University of Newcastle upon Tyne
University of the West of England, Bristol
Manchester Metropolitan University
University of Huddersfield
The University of Northampton
Bournemouth University
Sheffield Hallam University
Queen Margaret University College, Edinburgh
Coventry University
University of Essex
University of Lincoln
RoyalWelsh College of Music and Drama
University of Central University
Lancashire Napier University
King's College London
University of Southampton
University of Hertfordshire
University of Sunderland
Edge Hill University
Oxford Brookes University
St George's Hospital
University of Hull
Goldsmiths College,University of London
Roehampton University
Colchester Institute
University of Greenwich
University of York
Suffolk College
University of Brighton
University of Nottingham
Nottingham Trent University
Liverpool John Moores University
De Montfort University
University of Sheffield
London South Bank University
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